The general “drift” of what I was getting at is that changing a KX155A for a KX165A is unlikely to be noticed, because they look almost identical. And the average UK maintenance company doesn’t get involved with radio gear. The nearest they get to something “electrical” is starting the engine.
the avionics pull out the radio and check the reg. number
That is amazing, and isn’t going to do the equipment much good. For example an autopilot is likely going to have an airtight seal in the back of it (for the static connection, for altitude hold) and this is going to get pointlessly disturbed. There is a tiny o-ring which needs to be lubed with the correct grease and you can bet the shop collecting the serial numbers isn’t going to be doing that. It is a very stupid procedure. I would never want to be on the D-reg…
the avionics pull out the radio and check the reg. number
That is a bit obscure. My guy knows I’m paying him 800 € every year for exactly nothing and he wouldn’t do such a thing. As I said, if you want to do something off the books, don’t go to the #1 shop and ask them about it on the telephone, go to the average Joe avionics guy working out of his van.
Is it legal to do the next avionics check/maintenance in a foreign country if the regulations in GB, Denmark or Poland are less stupid ? Or has the check to be done in the country of registration ?
Any experiances ?
For D-reg the avionics checker needs to have LBA approval. So the answer is more or less no.
You should contact Jesse (on this forum). He does seem to have the LBA approval and his rates are definitely lower than those of most german Prüfers (who tend to charge “by the unit”…)
I do not have a minor change approval which I have to buy from a well known shop in southern Germany for 500 Euro. Isn`t it stupid ?
A minor change approval is just required by law. They where once free of charge, nowadays EASA charges around 300 Euro for the approval process to the applicant. The applicant have to create a “design” and prove that it meets the requirements. (For example, installation of a KX-155 to replace a KX-175 would be a no no, as this KX-155 does not meet the 8.33 kHz separation and is a replacement for a 25 kHz radio. Therefore doesn’t comply, and wouldn’t be approved). Make this data cost time. 500 Euro including VAT (and the 300 EASA fee) Most of it would be VAT and EASA fee.
You could do the minor change paper work all by your self and save lot’s of money. As mentioned earlier most of your money will end up as VAT or someones income tax.
/Sam
highflyer,
minor change approval is a fact of life and needs to be done. Otherwise the costs are going to be much higher if you are found illegal at a ramp check or at your next avionic check. Just get it done and then forget about it.
In Europe, you have exactly 2 choices. Either do what EASA tells you or stop flying.
Apply for a minor change can be done yourself, however you should be willing to spend time to find out the process and what they want to see. I sometimes do minor changes for other companies as well as they get stuck in the process and give up.
Does EASA publish guidance on how to make a decision in the field as to whether a proposed mod is Major or Minor?
It’s a Q I have asked and apparently there isn’t any guidance i.e. it is EASA who is the final arbiter and every mod must be referred to it for a judgement.
One EASA Part 21 (a design authority) shop owner told me they get some latitude to make that decision in-house.
I think that is bad because if you lay down rules you have a responsibility to publish them in a form which the average person (one that is required to apply them) is able to understand.
In practice the decision is often made in the field using common sense and if necessary the work is done “off the books”.
In the FAA system, there is clear guidance which covers most non-electronics areas, in Part 43 Appendix A (see e.g. “Certification” notes here). An old copy is here – see page 20+. The system is far from perfect and there are various bits elsewhere which cover the other stuff e.g. autopilot installations and subsequent interconnections. But it is clear enough for most jobs and the issue is in practice limited mostly by adult illiteracy issues because many people working on aircraft can’t read these docs.
